ANTI-MONEY LAUNDERING/COMBATING THE FINANCING OF TERRORISM

In order to protect the customers’ funds and ensure compliance with international standards, the Company carries out all appropriate measures on prevention and combating money laundering, terrorism financing and financing the proliferation of weapons of mass destruction (AML Policy).

Thus, the Company has a strong position to prevent all kinds of illegal activity. To fulfill these obligations, the Company is bound to inform competent authorities if there is a reason to suspect that funds which were deposited by the customer into his account are related to illegal activity or terrorism financing. The Company is also obliged to freeze such funds and to undertake measures provided for by the rules of the AML policy and applicable law.

The following defined terms are widely used in the industry:

Money Laundering: The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering and integration.

Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.

Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler’s checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets.

Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.

Suspicious Activity: Activity conducted by a customer using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.

In order to prevent the infiltration of criminal capital into the economy of the state, many countries fight against money laundering and the terrorism financing.

The Company applies internal laws and regulations and special measures to help international organizations in combating money laundering and the terrorism financing around the world.

In addition to the above, in compliance with anti-money laundering legislation, we inform you that any transaction equal to or exceeding USD 10,000 (or equivalent in your account currency) will be documented and reported to relevant regulatory authority.

When you open an account, you agree to undertake the following obligations:

You agree that you comply with all applicable laws and regulations on combating money laundering and terrorism financing, including the АМL Policy.

You confirm that you have no information or any suspicions about the fact that  funds used for depositing in the past, present or future, are received from any illegal source, or have any relation to legalization of income obtained illegally, or other unlawful activity prohibited by applicable law or the instructions of any international organizations.

You agree to immediately provide any information we think fit to require according to applicable laws and regulatory requirements in respect of combating the legalization of funds obtained illegally.

The Company collects and keeps the passport or other ID of the customer, and reports on all changes made in the account.

The Company monitors any suspicious activity on the customer’s account, as well as operations carried out under special conditions.

The Company has the right to ban the customer at any time, if the Company has grounds for supposing that this operation has any relation to money laundering and criminal activity. In accordance with international law the Company is not obliged to inform the customer about his suspicious activity and let him know that it has been passed to relevant authorities.

In accordance with the internal AML procedures the Company performs initial and ongoing personal identity verification procedures as provided by the level of risk of each customer.

The Company will ask you to provide the minimal information to confirm your identity.

The Company will record and preserve all data and ID, as well as which methods of confirmation have been used and the results of verification procedures.

The Company will check your personal data to match the list of persons suspected of terrorism, which is formed by the authorized state and independent authorities. A minimum set of identification data includes: the customer’s full name; date of birth; residential address and contact details of the customer;

Sources of funds that you plan to deposit into the account.

To verify and confirm the authenticity of the above-mentioned data, the Company may require the following documents:

passport or identification card, or other document equivalent, issued by the national public authorities, that meets the following requirements: contains the full name, date of birth and a photograph of the document holder; the document doesn’t expire in the next 3 months;

a recent utility bills or bank statement (issued within the last 3 months) or other documents confirming the address of the customer.

The Company may also require other additional information, confirmed by relevant documents. In certain cases, the Company may also require notarized copies of documents from customer.

All personal data will be destroyed when it is no longer required to be retained or by law.

This AML policy will be reviewed when deemed necessary to ensure it remains compliant with regulatory requirements and international standards.